REFERENCE / Responsibilities
Manufacturer, importer and distributor: who does what?
Map the legal role to the supply chain. Product branding, own use and modifications can change who carries manufacturer obligations.
The Directive remains the current framework before 20 January 2027. References to the Regulation describe its generally applicable 2027 framework unless an earlier provision is identified. This is independent educational information.
Manufacturer responsibilities
The Regulation’s manufacturer definition includes a person who makes a product, or has it designed or made, and markets it under their name or trademark. It also includes manufacturing for own use. A company need not operate the fabrication workshop itself to occupy this role.
For machinery and related products, Article 10 addresses design and construction, technical documentation, assessment, the EU declaration and CE marking. It also includes identification, instructions, ongoing series-production conformity and corrective action. A consultant can support the work; the manufacturer’s legal responsibility does not disappear because a report was outsourced.
Importer and distributor roles
An importer is established in the Union and places a product from a third country on the Union market. Article 13 sets duties for machinery and related products, including checks on the manufacturer’s conformity work and documents. Article 14 separately addresses partly completed machinery.
A distributor makes a product available in the supply chain while being neither manufacturer nor importer. Articles 15 and 16 distinguish their obligations for complete and partly completed products. Their role includes due care and relevant checks, not simply passing on a supplier’s assurance.
When the role changes
Article 17 applies manufacturer obligations to an importer or distributor that markets a product under its own name or trademark or modifies a product already placed on the market in a way that may affect compliance. Article 18 addresses substantial modification of machinery or a related product.
The authorised representative has a written mandate for specified tasks. The mandate cannot be assumed to transfer every manufacturer obligation. Identify the exact activity, product and legal provision before delegating a task.
A practical role map
Record the manufacturer identity, the Union importer where applicable, the distributor and any authorised representative. Keep contact details and identify who controls engineering changes, documentation and the final supplied configuration.
This is a map of roles under the future generally applicable Regulation, not a substitute for current Directive obligations or the separate EU market-surveillance framework. Different entities within one commercial group may have different roles for different products.
Sources & related reading
- Regulation (EU) 2023/1230, consolidated 27 July 2026: Articles 3 and 10–18.
- Directive 2006/42/EC, consolidated text: current framework.
- European Commission machinery legislation and guidance.
Continue with eu machinery law: the working framework, machinery regulation: the 2027 transition, machinery scope and product definitions.
Machine-specific interpretation and verification need competent assessment. This publication does not give legal advice or guarantee compliance.